FAA to TCCA transition
FAA to TCCA repair approval data transition review
This review reads the repair and alteration records behind an aircraft's damage history and asks whether each repair's approval basis will travel to the Canadian register. It is run for the receiving side, or the seller preparing the handover, before the repair map transfers. The work ties each repair to its damage report, disposition, and approved data, and confirms the return-to-service entry follows from that basis. You receive an evidence map keyed to the import questions, a gap list of repairs whose data will not travel as recorded, and a request set for the substantiation still to be recovered.
When this review is needed
- A US-registered aircraft is importing into Canada and its repair history has to be defensible for TCCA.
- A structural repair was accomplished on approved data whose Canadian standing is unclear.
- A damage report exists but the disposition and approved data behind the repair are not linked.
- The repair map has to be reconciled to the return-to-service entries before the register changes.
The problem
A repair is only as sound as the approved data it was performed to and the disposition that tied that data to the damage. On a US to Canadian import the receiving side reads each repair for whether its basis is present and acceptable, and repairs done years ago on data that made sense at the time can leave a thin trail: a return-to-service entry with no disposition behind it, or approved data referenced but never filed. What passed as a closed repair under one authority becomes a question of substantiation under the other.
What gets reviewed
- Each repair tied to its damage report and the disposition that dispositioned it
- Approved or acceptable data confirmed present for each repair
- Return-to-service entries checked to follow from the repair's approval basis
- Repairs assessed for whether their basis travels to the Canadian side
- Alterations distinguished from repairs where the record treats them as the same
- Repairs whose data will not travel identified and listed for follow-up
Scope this review
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What gets validated
- Each repair has approved or acceptable data present, not merely referenced
- The disposition ties the approved data to the specific damage repaired
- The return-to-service entry follows from the repair's stated basis
- The approval basis is one a Canadian import will accept, or is flagged if not
- Alterations are recorded with their own approval data rather than folded into repairs
Evidence normally required
- The repair map or list of repairs and alterations on the aircraft
- Damage reports and the dispositions behind each repair
- Approved or acceptable data referenced by each repair
- Return-to-service entries for the accomplished repairs
- Structural repair records and any engineering substantiation on file
Common discrepancies
- A repair with a return-to-service entry but no disposition or approved data filed
- Approved data referenced on a repair that is not present in the record set
- A structural repair whose approval basis does not carry to the Canadian side
- An alteration recorded as a repair without its own approval data
What is at stake
A repair whose approved data cannot be produced becomes an open item at import, and one that can force re-substantiation or, in the worst case, rework of the repair itself. A structural repair without a traceable basis is particularly costly, because rebuilding the engineering justification after the fact is far harder than confirming the data was on file. Left unaddressed, a handful of undocumented repairs can hold up the import.
How the work runs
Lay out the repair map
List each repair and alteration and the damage report it responds to.
Link disposition to data
Tie each repair to its disposition and the approved data behind it.
Check the return to service
Confirm each return-to-service entry follows from the repair's stated basis.
Flag what will not travel
Identify repairs whose data is missing or will not carry and request the substantiation.
What the buyer receives
- An evidence map linking each repair to its disposition and approved data
- A gap list of repairs whose basis will not travel as recorded
- A request set for the substantiation and disposition records still needed
Who uses the output
- Continuing-airworthiness teams clearing the repair history for the Canadian register
- Acquisition teams sizing the re-substantiation an import could require
- Records staff recovering the approved data and dispositions the import will demand
How the work fits into the transaction or program
The review reads the repair history before the import, so repairs with a thin basis are known while there is still time to recover the data or plan re-substantiation. Its gap list drives the recovery, and its evidence map forms the repairs section of the Canadian import package.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
A repair accomplished on FAA-acceptable data does not automatically carry an accepted basis on the Canadian side. The review distinguishes repairs whose data travels from those the receiving authority will want re-established, so the importer sees which repairs are a filing question and which are a substantiation question.
Regulatory limits
The review assesses the repair records and reports the gaps. It does not approve a repair, develop approved data, or make an airworthiness determination. Acceptance of the repair history rests with the receiving operator and TCCA.
What this review does not cover
- Performing or re-performing any repair or alteration
- Developing or approving repair or substantiation data
- Any airworthiness determination on the repairs or the aircraft
Specific to this review
- The frequent gap is a return-to-service entry with no disposition behind it, so the repair is recorded as closed but the link to its approved data is missing.
- Approved data referenced but never filed is a common trap, because the reference reads as complete until someone asks to see the data itself.
- A structural repair without a traceable basis is expensive to fix late, because re-substantiating the engineering after the fact costs far more than confirming the data was on file.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
U.S. Government (eCFR). Export airworthiness approval requirements and special requirements of an importing authority.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
What if a repair's approved data was acceptable to the FAA but not clearly to the Canadian side?
The review flags it as a repair whose basis needs re-establishing rather than a simple filing gap. From there the importer can retrieve or rebuild the substantiation, but the review does not approve any repair or develop the data itself.
Relevant glossary terms
Related pages
Where this fits
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We will walk through your current state, the records or evidence involved, and a scoped first engagement.
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